BEFORE THE PUBLIC UTILITIES COMMISSION

OF THE STATE OF CALIFORNIA FILED

7-11-17
04:59 PM
Application of California-American
Water Company (U210W) for Approval
of the Monterey Peninsula Water Application 12-04-019
Supply Project and Authorization to (Filed April 23, 2012)
Recover All Present and Future Costs in
Rates.
ADSFASDFAS ASDFSADF S ASDF ADS ASDFAS FSDAF

COMMENTS ON JOINT STATEMENT OF ISSUES

Pursuant to Administrative Law Judges Ruling Requesting Parties to Identify

Issues for Further Evidentiary Hearings (the Ruling) and subsequent email rulings 1
granting an extension of time to file Statement of Issues and comments, the Office of
Ratepayer Advocates (ORA) submits these comments on the Joint Statement of Issues
filed on June 20, 2017.
ORA appreciates the Commission revisiting the evidence necessary to determine
whether California-American Water Companys (Cal-Am) application for a Certificate of
Public Convenience and Necessity (CPCN) for the construction and operation of a
desalination plant and related facilities, otherwise called the Monterey Peninsula Water
Supply Project (MPWSP), is a reasonable and prudent means of securing an adequate,
reliable, safe, and cost-effective water supply that meets Cal-Ams legal requirements for
the Monterey District; required for public convenience and necessity; and in the public
interest.2 As the Commission has previously recognized, the current cost estimates
for the MPWSP as well as current regional water demand and supply are necessary for

1
Administrative Law Judge email rulings dated June 14, 2017 and June 15, 2017.
2
Assigned Commissioners Scoping Memo dated June 28, 2012, p. 2; Amended Scoping Memo dated
September 25, 2013, p.2; Third Amended Scoping Memo dated November 21, 2016, p. 3.

192002954
the Commission to reach a well-informed decision.3 It is prudent for the Commission to
re-assess data and information that may have changed due to the passage of time and
changed circumstances that is relevant in determining the reasonableness and prudence of
the MPWSP.
At this time, it is appropriate for the Commission to:

1) Gather current demand data and changes in present demand as

compared to data previously presented for the Monterey District,
including but not limited to, non-revenue water, lots of record,
pebble beach allotments, general plan build out, and tourism bounce
back;
2) Gather updated information on existing and potential sources and
corresponding volumes of supply and a description of the constraints
of each supply source for the Monterey District, including but not
limited to, diversions from the Carmel River, aquifer storage and
recovery, seaside basin, sand city desalination plant, Ground Water
Replenishment (GWR), and the potential of expansion of GWR;
3) Gather updated MPWSP project information, including design
updates based on test well data; and
4) Evaluate updated cost information based on current project status,
including test well data.

3
Administrative Law Judges Ruling Settling Evidentiary Issues and Schedule to Complete the Record
for Phases 1 and 2 dated November 17, 2015, pp.4-5.

2
 Respectfully submitted,

/s/ VANESSA M. YOUNG

Vanessa M. Young

Attorney for
The Office of Ratepayer Advocates

California Public Utilities Commission

505 Van Ness Avenue
San Francisco, CA 94102
Phone: (415) 703-3942
July 11, 2017 Email: Vanessa.Young@cpuc.ca.gov